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In July 2019 the IRS identified post offshore voluntary disclosure program (OVDP) compliance as a campaign. The purpose of the campaign is to pursue those OVDP participants who fail to remain compliant with their foreign income and asset reporting requirements. The campaign said that the IRS would address this tax noncompliance through soft letters and examinations. OVDP participants have recently received such soft letters.

Continue reading the full GT Alert, “Your Offshore Voluntary Disclosure May Be Long Over but the IRS May Be Looking at Your Ongoing Tax Compliance.”

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Photo of Barbara T. Kaplan Barbara T. Kaplan

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals…

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.

Photo of Jared E. Dwyer Jared E. Dwyer

Jed Dwyer focuses his practice on white collar criminal matters, criminal and civil tax litigation, and other complex civil litigation. Jed has tried more than 40 jury and non-jury trials and has been involved in over 100 investigations and prosecutions, many of which

Jed Dwyer focuses his practice on white collar criminal matters, criminal and civil tax litigation, and other complex civil litigation. Jed has tried more than 40 jury and non-jury trials and has been involved in over 100 investigations and prosecutions, many of which included complex fraud and regulatory matters. Jed leverages his experience to represent individuals and organizations in investigations and other proceedings concerning tax fraud, money laundering, public corruption, complex international financial crime, financial institution fraud, and violations of the Bank Secrecy Act, among others.

Prior to joining the firm, Jed served for ten years as a federal prosecutor, first as a trial attorney with the U.S. Department of Justice, Criminal Enforcement Section, Tax Division, which Jed joined through the Attorney General’s Honors Program, and then as an Assistant United States Attorney at the U.S. Attorney’s Office for the Southern District of Florida. As a trial attorney at the Tax Division, Jed handled all aspects of complex tax fraud investigations and prosecutions in districts throughout the country. As an Assistant United States Attorney, Jed concentrated on the investigation and trial of white collar crimes, including mail and wire fraud, public corruption, money laundering and Bank Secrecy Act violations. Jed routinely worked closely with FinCEN, the OCC, and the IRS in criminal and regulatory matters involving financial institutions.

Photo of Michelle Ferreira Michelle Ferreira

G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California

G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county assessment appeals boards.

As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages.

Michelle has 18 reported decisions in the U.S. Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions, and unsubstantiated business expenses.

Photo of Scott E. Fink Scott E. Fink

Scott E. Fink focuses on civil and criminal federal and state tax controversies and litigation. He represents corporations, partnerships, estates and individuals before the Internal Revenue Service, and state and local tax authorities in examinations, collection problems, administrative appeals, and in court.

Photo of Courtney A. Hopley Courtney A. Hopley

Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes.

Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes. Courtney also has experience in tax planning involving entity formation, mergers and acquisitions, and reorganization transactions.

Photo of Jennifer A. Vincent Jennifer A. Vincent

Jennifer A. Vincent is an associate in the Audits, Litigation & Criminal Tax Defense Group, focusing on federal and state tax controversies and litigation. Ms. Vincent represents both individuals and companies in proceedings before the Internal Revenue Service and before California taxing authorities…

Jennifer A. Vincent is an associate in the Audits, Litigation & Criminal Tax Defense Group, focusing on federal and state tax controversies and litigation. Ms. Vincent represents both individuals and companies in proceedings before the Internal Revenue Service and before California taxing authorities, including the Franchise Tax Board and the California Department of Tax and Fee Administration. She also assists clients with compliance counseling for both federal and state-based tax issues.

Ms. Vincent has considerable experience in defending clients in federal offshore audits and income tax examinations and in California income, sales and use tax, and property tax matters.

Photo of Shira Peleg Shira Peleg

Shira Peleg is an Associate in Greenberg Traurig’s Tax Practice. She represents clients before the Internal Revenue Service and state and local taxing authorities in examinations, appeals, court, and collections.